As long as the company is filing through "alternative" methods, meaning it is Pink Current, it can issue a dividend. Although, FINRA has recently been under no obligation to approve or cater to such requests.
Can a non reporting company even issue a dividend?
Yes. Although it's rare for a Pinky to ever issue it as cash. ORFG chose the usual of issuing restricted stock.
Most of these Pinkies ever have more than 100 shareholders.
They can authorize as many shares as they wish. For ORFG it's a simple matter of submitting a form with a filing fee to the Nevada Sec of State office. Currently the A/S count is set at 850M. The amount also stated in their Apr OTC filing covering end of Feb. Up from 250M A/S for the period ending in Nov, and filed in Jan. Issued shares hit 303M by the end of Feb.